The appellant, Tajinder Singh Pawar, went to the tribunal to ask for permission to notify a late appeal over a personal liability notice (PLN) issued by HMRC in 2017, which totalled £874,238. 

However, Pawar waited more than 1,155 days (38 months) after the statutory time limit of 30 days to file his notice of appeal.

On 5 October 2017, HMRC wrote to First Stop Wholesale Limited with a personal liability notice (PLN), along with a cover letter.

The penalty was imposed for errors HMRC identified in the company’s VAT returns.

The amount of the PLN was £874,238, which Pawar was personally liable to pay by 4 November 2017 and stated that any request for a review should be received by that date.